U.
S.
A.
CUN2003/
062
­
TOMATO
 
FIELD
TOMATOES
GROWN
OUTDOORS
ON
PLASTIC
MULCH
TABLE
OF
CONTENTS
Introduction
................................................................................................................................
2
Critical
Need
for
Methyl
Bromide...............................................................................................
2
Response
to
Questions
from
MBTOC/
TEAP
..............................................................................
4
Historical
Emission
Reduction
Tables
&
MB
Dosage
Rates......................................................
10
Virtually
Impermeable
Film
(
VIF)
Tarps
..................................................................................
11
Market
Window
Information.....................................................................................................
13
Definitions:
...............................................................................................................................
15
References:
...............................................................................................................................
16
LIST
OF
TABLES
Table
1.
Region,
Key
Pests,
and
Critical
Need
for
Methyl
Bromide
...........................................
2
Table
2.
Measures
of
Economic
Impact
on
Fresh
Market
Tomatoes
in
the
U.
S...........................
3
Table
3.
Historical
Use
of
Methyl
Bromide
in
the
Tomato
Sector...............................................
6
Table
4.
Calculation
of
the
Nominated
Amount
of
Methyl
Bromide
in
the
Tomato
Sector..........
7
Table
5.
Herbicides
Registered
in
the
United
States
to
Control
Nutgrass
in
Tomatoes
................
9
Table
6.
Fumigant
Alternatives
to
Methyl
Bromide
for
Polyethylene­
Mulched
Tomato
(
Locascio
et
al.,
1997)
...................................................................................................................
10
Page
2
INTRODUCTION
The
U.
S.
nomination
for
tomato­
fields
(
CUN2003/
062)
is
a
critical
need
only
for
an
amount
of
methyl
bromide
(
MB)
associated
with
moderate
to
severe
pest
pressure
(
principally
nutsedge
for
Florida,
Georgia,
Southeastern
USA,
and
Virginia
and
Phytophthora
for
Michigan)
(
see
Table
1)
because
there
are
no
feasible
alternatives
and
farmers
face
economic
harm
in
relying
solely
on
alternatives.
Alternatives
for
tomatoes
fail
to
provide
necessary
pest
control
for
moderate
to
severe
pest
pressure.
The
nomination
also
notes
that
applying
alternatives
is
further
complicated
when
plant­
back
restrictions
prevent
farmers
from
meeting
marketing
windows
(
e.
g.
winter
or
early
spring)
when
tomato
sale
prices
are
as
much
as
100%
higher
than
during
the
rest
of
the
year
(
see
Market
Window
Information).
The
nomination
notes
tremendous
progress
in
adopting
emission
reduction
technologies
and
changing
formulations
and
application
rates
to
reduce
MB
dosage
rates
to
some
of
the
lowest
in
the
world,
and
that
further
trials
are
being
conducted
to
test
ways
of
overcoming
constraints
in
further
lowering
MB
dosage
rates
using
more
impermeable
barriers.

CRITICAL
NEED
FOR
METHYL
BROMIDE
TABLE
1.
REGION,
KEY
PESTS,
AND
CRITICAL
NEED
FOR
METHYL
BROMIDE
U.
S.
Region
/
State
Key
Pests
Critical
Need
for
Methyl
Bromide
Florida
(
CUE
02­
0046)

Georgia
(
CUE
02­
0047)

Southeastern
U.
S.
(
CUE
02­
0040)
Alabama,
Arkansas,
North
Carolina,
South
Carolina
and
Tennessee
Virginia
(
CUE
02­
0012)
Diseases:
Phytophthora,
Pythium,
Verticillium,
Fusarium
spp.,
Rhizoctonia
spp.,
Sclerotium
rolfsii
Nematodes:
Root­
knots
(
Meloidogyne
spp.,
Pratylenchus,
Rotylenchus,
Belonolaimus).

Weeds:
Purple
and
yellow
nutsedge
(
Cyperus
spp.),
nightshades
(
Solanum
spp.)
and
broad
leaf
weeds.
At
moderate
to
severe
pest
pressure
only
MB
can
effectively
control
the
target
pests
(
especially
nutsedge)
found
in
the
southeast
U.
S.
In
addition,
for
some
areas
in
Florida
the
use
of
alternatives
is
limited
because
the
soil
overlays
a
vulnerable
water
table
(
karst
topography).
Finally,
regulatory
restrictions
such
as
mandatory
buffers
around
inhabited
structures
also
limit
the
use
of
alternatives.
MB
applications
in
tomatoes
are
typically
made
using
67:
33
mixture
with
chloropicrin
(
or
lower
where
feasible)
under
plastic
mulch.

Michigan
(
CUE
02­
0004)
Diseases:
Phytophthora
capsici
Wilts:
Verticillium
spp.,
and
Fusarium
oxysporum
f.
sp.
Lycopersicae.
At
moderate
to
severe
pest
pressure
only
MB
can
effectively
control
the
target
pests
in
Michigan.
Under
Michigan
climatic
conditions,
the
alternatives
do
not
effectively
control
the
dominant
pest,
Phytophthora
capsici.
MB
applications
in
tomatoes
are
typically
made
using
67:
33
mixture
with
chloropicrin
(
or
lower
where
feasible)
under
plastic
mulch.

California
(
CUE
02­
0006)
Application
withdrawn
Page
3
ECONOMIC
IMPACTS
In
order
to
determine
whether
a
proposed
alternative
to
MB
is
considered
to
be
`
economically
feasible'
for
those
situations
where
technically
feasible
alternatives
exist,
the
United
States
took
a
`
weight
of
the
evidence'
or
`
portfolio'
approach.
Rather
than
rely
on
a
single
indicator
or
even
a
series
of
indicators,
each
with
a
`
bright
line',
the
situation
of
the
applicant
with
respect
to
five
measures
was
assessed.
The
five
measures
selected
for
consideration
were:
loss
per
hectare;
loss
per
kilogram
of
MB;
loss
as
a
percent
of
gross
revenue;
loss
as
a
percent
of
net
cash
returns;
and
change
in
profit
margins.
These
measures
were
selected
because
the
information
was
fairly
readily
available,
they
describe
different
aspects
of
potential
loss
and
are
independent
of
each
other.
In
cases
where
information
was
not
available
for
one
or
more
of
the
measures,
the
remaining
measures
were
used.
In
cases
where
a
stream
of
benefits
was
derived
from
a
MB
application,
net
present
value
was
used
in
the
calculations.

When
evaluating
the
case
made
by
each
application,
expert
economic
judgment
was
used
to
determine
whether
each
loss
(
or
change
in
profit
margin)
was
significant,
not
significant,
or
borderline
within
the
context
of
the
applicant's
market.
Once
decisions
on
individual
measures
were
reached,
an
overall
assessment
was
made
which
included
the
individual
measures.

The
original
U.
S.
nomination
presented
data
showing
that
the
next
best
alternative
to
MB
is
not
economically
feasible
in
the
circumstances
of
each
of
the
nominated
states/
regions.
In
Michigan,
the
economics
of
the
next
best
alternative
1,3­
D
and
chloropicrin
was
analyzed
and
showed
a
$
97
loss
per
kilogram
MB
replaced.
Other
economic
measures
also
show
that
the
adoption
of
the
alternative
would
lead
to
significant
impacts
on
economic
profitability.
In
the
Southeast
region
including
Florida,
Georgia,
and
Virginia,
the
economic
loss
based
on
up
to
15%
yield
loss
was
estimated
$
30.55
per
kilogram
of
MB
replaced.
The
economic
measures
of
gross
revenue
and
net
cash
return
also
demonstrate
that
a
substantial
decline
in
the
growers'
economic
profitability
would
occur.
Given
the
competitive
nature
of
fresh
tomato
production
in
the
United
States,
these
economic
impacts
render
the
use
of
alternatives
economically
infeasible
for
U.
S.
fresh
tomato
producers.

TABLE
2.
MEASURES
OF
ECONOMIC
IMPACT
ON
FRESH
MARKET
TOMATOES
IN
THE
U.
S.

Loss
Measure
Michigan**
Southeast
including
FL,
GA
and
VA
Direct
Yield
Loss
20
 
30%
5
­
15%

Loss
Per
Hectare
$
10,550
$
950
 
$
6,721
likely
$
2,230
Loss
Per
Kilogram
MB
$
97
$
11.10
 
$
30.55
likely
$
13.70
Loss
as
%
of
Gross
Revenue
31%
7
­
16%
likely
9%

Loss
as
%
of
Net
Cash
Returns
160%
87
 
112%
likely
109%
**
The
economic
measures
were
calculated
for
the
projected
yield
loss
of
25%.
Analysis
for
Michigan
is
based
on
using
1,3­
D
and
Chloropicrin
as
the
MB
alternative
treatment.
Analysis
for
Southeast
(
including
FL,
GA
and
VA)
region
is
based
on
using
1,3­
D,
chloropicrin,
and
pebulate
as
the
MB
alternative.
However,
pebulate
is
no
longer
available,
and
without
an
effective
herbicide,
losses
are
expected
to
be
much
more
substantial
than
those
noted
above.
In
both
cases,
these
data
demonstrate
that
the
best
available
alternatives
to
MB
are
economically
infeasible.
Page
4
RESPONSE
TO
QUESTIONS
FROM
MBTOC/
TEAP
1.
The
Party
is
requested
to
detail
the
reasoning
and
assumptions
used
to
calculate
the
nominated
amount.

The
details
of
the
reasoning
and
assumptions
used
to
calculate
the
nominated
amount
are
shown
in
Table
4.

The
methodology
used
by
the
U.
S.
carefully
scrutinized
applications
from
the
user
community
and
took
out
(
1)
double
counting;
(
2)
any
requested
growth
beyond
historical
acreage
planted,
and
(
3)
requested
amounts
that
fall
under
QPS.
Furthermore,
the
United
States
adjusted
the
requests
from
the
user
community,
when
they
had
not
already
done
so,
to
change
the
amount
of
MB
nominated
to
account
for
(
1)
only
the
area
where
pest
pressure
cannot
be
controlled
by
alternatives,
(
2)
the
area
where
regulatory
constraints
limit
adoption
of
alternatives,
such
as
buffers
near
inhabited
areas,
and
(
3)
the
area
where
soil/
geological
features
limit
use
of
alternatives,
such
as
groundwater
contamination
in
areas
with
karst
topography.
The
nominated
amount
incorporates
minimum
efficacious
use
rates,
mixtures
of
MB
with
chloropicrin,
and
the
use
of
tarps
to
improve
efficacy
and
reduce
emissions.

2.
Also
to
list
the
registration
of
herbicides
for
this
crop
and
provide
data
on
why
these
are
not
suitable
for
nutgrass
control
(
the
main
reason
why
MB
is
used
in
the
southeastern
USA).

The
herbicides
with
activity
against
nutsedge
species
that
are
currently
registered
for
use
in
the
United
States
are
provided
in
Table
5.
These
herbicides
are
phytotoxic
to
tomatoes
under
certain
conditions
and
impose
severe
crop
rotation
restrictions
on
subsequent
crops
(
for
full
description
please
see
pages
9
and
10).

3.
As
the
CUN
specifically
requests
MB
for
areas
where
nutgrass
exists
as
heavy
infestations,
the
Party
is
requested
to
clarify
the
exact
amount
of
MB
required
for
this
use
and
to
validate
the
amount
of
MB
required
for
those
areas
where
1,3­
D
is
not
available
through
local
restrictions
(
e.
g.,
township
caps,
karst
topography).

The
steps
to
calculate
the
nominated
amount
are
shown
in
Table
4,
and
the
details
of
the
reasoning
and
assumptions
and
the
citations
for
these
conclusions
are
explained
in
Question
1
and
the
text
following
the
table.

4.
It
is
also
requested
that
the
Party
consider
recalculating
the
quantity
nominated,
consistent
with
the
use
of
emission
control
technologies
coupled
with
minimizing
MB
dosages,
such
as
when
applied
in
conjunction
with
chloropicrin
where
feasible.

The
U.
S.
nomination
accounts
for
the
historical
efforts
by
tomato
growers
to
reduce
emissions
and
to
reduce
MB
dosages
as
described
in
the
section
"
Historical
Emission
Reduction
and
MB
Dosage
Rates"
shown
below,
and
therefore
does
not
need
to
be
recalculated.
The
section
demonstrates
notable
success
in
the
United
States
at
efficiently
using
MB
at
low
dosages
with
emission
control
technologies
to
control
key
pests.
As
the
Page
5
2002
MBTOC
report
states,
"
in
some
countries
(
e.
g.,
the
USA)
the
potential
for
reducing
MB
dosages
for
soil
fumigation
compared
to
many
other
countries
will
be
less
because
dosages
are
already
low."

Growers
requesting
this
exemption
have
routinely
used
plastic
tarpaulins
since
the
1980s
to
reduce
MB
emissions
and
maximize
MB
effectiveness.
Recent
efforts
have
continued
to
try
to
maximize
each
quantity
of
MB,
using
formulations
of
MB/
Pic
with
lower
MB
proportions
and
continued
testing
of
VIF
tarps.
The
difficulties
and
impediments
in
adopting
VIF
tarps
are
being
investigated
in
the
United
States
and
are
described
on
page
11.
The
U.
S.
nomination
assumes
that
growers
will
continue
to
use
a
67:
33
mixture
of
MB
with
chloropicrin,
therefore
we
have
not
recalculated
the
nomination
amount
because
the
U.
S.
nomination
already
took
into
account
the
application
of
minimal
doses
and
the
use
of
emission
control
technologies.

5.
MBTOC
is
unable
to
recommend
a
CUE
on
the
basis
of
the
available
information,
but
notes
that
control
of
nutgrass
is
difficult
where
herbicides
or
other
measures
cannot
be
used
and
there
are
areas
where
alternatives
are
not
available
through
local
restriction
(
e.
g.,
township
caps).

The
amounts
of
MB
nominated
are
for
areas
where
there
is
moderate
to
severe
key
pest
pressure
(
nutsedge
for
Florida,
Georgia,
the
southeast,
and
Virginia;
Phytophthora
for
Michigan)
and
control
cannot
be
achieved
without
MB.
Details
of
the
analysis
are
presented
in
Table
4.

6.
It
is
also
requested
that
the
Party
calculate
the
revised
amount
consistent
with
the
use
of
low
dosages
of
MB
in
formulations
such
as
MB/
Pic
(
67:
33
or
50:
50).

U.
S.
growers
continue
to
test
formulations
with
lower
MB,
as
well
as
test
practices
with
VIF.
Other
emission­
reducing
strategies,
such
as
the
use
of
LDPE
and
HDPE
plastic
tarps,
are
in
routine
use.
As
the
2002
MBTOC
report
states,
"
in
some
countries
(
e.
g.,
the
USA)
the
potential
for
reducing
MB
dosages
for
soil
fumigation
compared
to
many
other
countries
will
be
less
because
dosages
are
already
low."
In
past
trials
when
MB
and
chloropicrin
are
used
in
a
50:
50
combination
it
tends
to
increase
plant
vegetative
growth
at
the
expense
of
fruit/
vegetable
production.
This
characteristic
is
desirable
for
orchard
replant
but
highly
undesirable
for
annual
crops
(
personal
communication
with
Sally
Schneider,
Agricultural
research
Service,
US
Department
of
Agriculture;
and
Michael
V.
McKenry,
University
of
California.
Riverside,
Parlier,
California).
Although
many
sectors
continue
to
test
the
50:
50
combination,
this
formulation
has
not
given
good
results
in
tested
cropping
conditions
because
it
provides
less
weed
control
and
there
is
increased
vegetative
growth
by
the
weeds
that
survive.

7.
The
nomination
noted
that
a
range
of
alternatives
was
considered
technically
feasible
for
areas
of
low
inoculum
levels
of
pathogen
and
weeds
(
e.
g.,
1,3­
D/
Pic
and
metham
sodium).
Formulations
of
metham
sodium
are
proving
effective
at
least
in
some
regions.

We
agree,
and
as
a
consequence,
MB
was
requested
only
for
areas
of
moderate
to
severe
key
pest
pressure
where
alternatives
will
not
work
because
they
do
not
control
the
pests
and/
or
because
they
are
restricted
due
to
regulatory
or
soil
considerations.
1,3­
Page
6
dichloropropene
is
restricted
from
use
in
soils
underlain
by
karst
topography
and
sandy
(
porous)
sub­
soils,
because
these
geological
features
­
common
in
the
parts
of
the
Southeastern
United
States
­
could
lead
to
ground­
water
contamination.
See
the
Reregistration
Eligibility
Decision
(
RED)
for
1,3­
D
(
U.
S.
EPA
1998).

A
field
study
on
tomatoes
in
Florida
(
see
Table
6
below)
with
high
nutsedge
pressure
(
300
plants/
m
²
for
the
nontreated
control)
showed
that
yield
losses
of
30
percent
could
be
expected
with
1,3­
D
+
17
%
chloropicrin
as
compared
to
the
MB
+
chloropicrin
formulation
(
67:
33).
In
the
same
study,
nutsedge
populations
were
also
significantly
higher
for
1,3­
D
+
chloropicrin
(
340
nutsedge
plants/
m
²
)
,
as
compared
to
MB
+
chloropicrin
(
90
nutsedge
plants/
m
²
)
.
It
should
be
noted
that
this
study
also
contained
a
treatment
with
1,3­
D
+
chloropicrin
+
pebulate
and
that
the
results
in
yields
that
were
not
significantly
different
from
MB
+
chloropicrin,
indicating
that
1,3­
D
+
chloropicrin
may
be
feasible
once
a
suitable
herbicide
alternative
is
found
and
registered
on
the
affected
crops
(
Locasio
et
al.,
1997).
However,
pebulate
is
no
longer
registered
in
the
United
States.

The
combination
of
1,3­
D
and
metam
sodium
is
not
widely
used
in
the
U.
S.
because:
(
a)
mixing
1,3­
D
with
metam
sodium
does
not
control
any
of
the
key
pest
species
that
1,3­
D
alone
will
not
control,
(
b)
heavy
soil
and
karst
topography
in
Florida
limit
the
use
of
1,3­
D,
whether
this
chemical
is
used
alone
or
in
combination
with
metam
sodium
(
c)
adding
metam
sodium
to
1,3­
D
will
not
provide
affective
disease
control,
in
areas
where
there
is
only
a
single
drip
irrigation
tape
used,
in
those
cases
1,3­
D
needs
to
be
shank
injected
with
metam
sodium
sprayed
on
the
surface
of
the
bed
and
then
mechanically
incorporated
(
a
multi
step
process),
and
(
d)
there
are
different
moisture
requirements
for
1,3­
D
and
metam
sodium.

TABLE
3.
HISTORICAL
USE
OF
METHYL
BROMIDE
IN
THE
TOMATO
SECTOR*.

Historical
Use
Average
Use
Rates
(
kg/
ha)
Total
Amount
(
kg)
Area
Treated
(
ha)

1997
201
3,891,129
18,054
1998
200
4,191,405
19,664
1999
173
3,750,983
20,443
2000
164
3,544,988
20,869
2001
155
5,172,080
32,366
*
Acres
(
fresh
market)
planted
in
U.
S.
are
130,520
(
52,819
ha).
Percent
of
U.
S.
fresh
market
tomato
acreage
requested
in
the
U.
S.
CUE
nomination
is
34%
of
total
acreage
(
17,917/
52,819=
34%).
Source:
Rates,
amounts,
and
area
treated
are
from
applicants'
information.
Percent
of
U.
S.
acreage
is
from
USDA,
2001.
National
Agricultural
Statistics
Service,
Agricultural
Statistics
2001.

.
Page
7
Table
4.
CALCULATION
OF
THE
NOMINATED
AMOUNT
OF
METHYL
BROMIDE
IN
THE
TOMATO
SECTOR
Calculation
of
Nominated
Amount
0004
 
Michigan
Solanaceous
0006
 
California
Tomato
Commission
Application
Withdrawn
0012
 
Virginia
Tomato
Growers
0040
 
Southeastern
Tomato
Commission
0046
 
Florida
Fruit
and
Vegetable
Association
 
Tomato
0047
 
GA
Fruit
and
Vegetable
Grower
Association
 
Tomato
Hectares
(
ha)
435
 
2,428
6,010
21,230
2,412
%
of
Regional
hectares
(
ha)(
A)
41
 
150
124
118
100
Applicant
Request
for
2005
Kilograms
(
kg)
of
MB
52,348
 
453,592
902,603
3,326,644
362,257
Double
Counted
hectares
(
ha)(
B)
 
 
 
 
 
 
Growth
/
Increasing
Production
hectares
(
ha)(
C)
(
33)
 
390
 
 
196
Quarantine
and
Pre­
Shipment
hectares
(
ha)(
D)

 
 
 
 
 
 
Adjustments
to
Request
Adjusted
Hectares
Requested
(
ha)(
E)

435
 
2,038
6,010
21,230
2,216
Key
Pest
Impacts
(%)(
F)
100
 
30
15
50
50
Regulatory
Impacts
(%)(
G)
0
 
0
0
1
0
Soil
Impacts
(%)(
H)
0
 
0
0
40
0
Impacts
to
Adjusted
Hectares
Total
Combined
Impacts
(%)(
I)
100
 
30
15
70
50
Qualifying
Area
(
ha)(
J)
435
 
612
901
14,861
1,108
Use
Rate
(
kg/
ha)(
K)
120
 
187
150
157
150
CUE
Amount
Nominated
(
kg)(
L)
52,348
 
114,237
135,390
2,328,650
166,389
%
Reduction
from
Initial
Request
(
M)
0
 
75
85
30
54
Sum
of
all
CUE
Nominations
in
Sector
(
kg)(
N)
2,797,015
Multiplier
for
Margin
of
Error
(
O)
1.0244
Total
U.
S.
Sector
Nomination
(
kg)(
P)
2,865,262
Page
8
Footnotes
for
Table
4:

Values
may
not
sum
exactly
due
to
rounding.

A.
Percent
of
regional
hectares
is
the
area
in
the
applicant's
request
divided
by
the
total
area
planted
in
that
crop
in
the
region
covered
by
the
request
as
found
in
the
USDA
National
Agricultural
Statistics
Service
(
NASS).
Note,
however,
that
the
NASS
categories
do
not
always
correspond
one
to
one
with
the
sector
nominations
in
the
U.
S.
CUE
nomination
(
e.
g.,
roma
and
cherry
tomatoes
were
included
in
the
applicant's
request,
but
were
not
included
in
NASS
surveys).
Values
greater
than
100
percent
are
due
to
the
inclusion
of
these
varieties
in
the
U.
S.
CUE
request
that
were
not
included
in
the
USDA
NASS:
nevertheless,
these
numbers
are
often
instructive
in
assessing
the
requested
coverage
of
applications
received
from
growers.
B.
Double
counted
hectares
is
the
area
counted
in
more
than
one
application
or
rotated
within
one
year
of
an
application
to
a
crop
that
also
uses
MB.
There
was
no
double
counting
in
this
sector.
C.
Growth
/
increasing
production
hectares
is
the
amount
of
area
requested
by
the
applicant
that
is
greater
than
that
historically
treated
or
treated
at
a
higher
use
rate.
Values
in
parentheses
indicate
negative
values
and
are
shown
to
demonstrate
a
trend,
but
are
not
used
in
further
calculations.
Two
applicants
included
growth,
which
was
removed.
D.
Quarantine
and
pre­
shipment
(
QPS)
hectares
is
the
area
in
the
applicant's
request
subject
to
QPS
treatments.
Not
applicable
in
this
sector.
E.
Adjusted
hectares
requested
is
the
hectares
in
the
applicant's
request
minus
the
acreage
affected
by
double
counting,
growth
/
increasing
production,
and
quarantine
and
pre­
shipment.
F.
Key
pest
impacts
is
the
percent
(%)
of
the
requested
area
with
moderate
to
severe
pest
problems.
Key
pests
are
those
that
are
not
adequately
controlled
by
MB
alternatives.
Key
pests
in
Michigan
affect
100%
of
the
acreage
because
Michigan
has
only
applied
for
acreage
where
Phytophthora
is
endemic.
For
the
remainder
of
the
applications
the
key
pest
is
nutsedge.
G.
Regulatory
impacts
is
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
legally
used
(
e.
g.,
township
caps)
pursuant
to
state
and
local
limits
on
the
use
of
alternatives
intended
for
the
protection
of
human
health
or
the
environment.
The
small
regulatory
restriction
for
the
Florida
application
is
due
to
the
30
meter
buffer
around
inhabited
structures.
H.
Soil
impacts
is
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
used
due
to
soil
type
(
e.
g.,
heavy
clay
soils
may
not
show
adequate
performance).
Florida
has
approximately
40%
karst
topography
where
1,3­
D
cannot
be
used
due
to
potential
for
groundwater
contamination.
I.
Total
combined
impacts
is
the
percent
(%)
of
the
requested
area
where
alternatives
cannot
be
used
due
to
key
pest,
regulatory,
or
soil
impacts.
In
each
case
the
total
area
impacted
is
the
area
that
is
impacted
by
one
or
more
of
the
individual
impacts.
For
each
application
the
assessment
was
made
by
biologists
familiar
with
the
specific
situation
and
able
to
make
judgments
about
the
extent
of
overlap
of
the
impacts.
For
example,
in
some
situations
the
impacts
are
mutually
exclusive
 
in
heavy
clay
soils
1,3D
will
not
be
effective
because
it
does
not
penetrate
these
soils
evenly,
but
none
of
the
heavy
soil
areas
will
be
impacted
by
township
(
regulatory)
caps
because
no
one
will
use
1,3D
in
this
situation,
so
this
soils
impact
must
be
added
to
the
township
cap
regulatory
impact
in
a
California
application.
In
other
words
there
is
no
overlap.
In
other
situations
one
area
of
impact
might
be
a
subset
of
another
impact.
In
these
cases,
the
combined
impact
is
equal
to
the
largest
individual
impact.
J.
Qualifying
area
(
ha)
is
calculated
by
multiplying
the
adjusted
hectares
requested
by
the
total
combined
impacts.
K.
Use
rate
is
the
requested
use
rate
for
2005.
This
rate
may
be
adjusted
downward
based
on
historical
use
patterns.
L.
CUE
amount
nominated
is
calculated
by
multiplying
the
qualifying
area
by
the
use
rate.
M.
Percent
reduction
from
initial
request
is
the
percentage
of
the
initial
request
that
did
not
qualify
for
the
CUE
nomination.
N.
Sum
of
all
CUE
nominations
in
sector.
Self­
explanatory.
O.
Multiplier
for
margin
of
error.
This
amount
is
one
percentage
point
of
the
original
(
1991)
baseline
amount.
This
factor
is
intended
to
compensate
for
the
compounding
influence
of
using
the
low
end
of
the
range
for
all
input
parameters
in
the
calculation
of
the
US
nomination
(
i.
e.,
using
the
lowest
percent
impact
on
the
lowest
number
of
acres
at
the
lowest
dosage
is
likely
to
result
in
values
that
are
unrealistically
too
small).
The
U.
S.
nominated
included
some
sectors
for
100%
of
the
amount
requested,
therefore
the
portion
of
the
multiplier
from
these
sectors
were
added
equally
across
all
other
sectors
resulting
in
a
final
multiplier
of
1.0244,
or
a
2.44%
increase
from
the
calculated
amount,
to
these
remaining
sectors.
P.
Total
U.
S.
sector
nomination
is
calculated
by
multiplying
the
summed
sector
nominations
by
the
margin
of
error
multiplier.
Page
9
TABLE
5.
HERBICIDES
REGISTERED
IN
THE
UNITED
STATES
TO
CONTROL
NUTGRASS
IN
TOMATOES
Herbicide
U.
S.
Registration
Status*
Major
Comments
Halosulfuron­
methyl
Yes
Potential
crop
injury;
plant
back
restrictions
Pebulate
No
Was
registered
for
use
in
tomatoes
but
registration
lapsed
December
31,
2002
S­
metolachlor
Yes
Not
registered
in
some
states
of
concern;
does
not
control
purple
nutsedge
Glyphosate
Yes
Non­
selective;
will
not
control
nutsedge
in
the
plant
rows;
does
not
provide
residual
control
Paraquat
Yes
Non­
selective;
will
not
control
nutsedge
in
the
plant
rows;
does
not
provide
residual
control
Rimsulfuron
Yes
Only
suppresses
nutsedge;
rotational
restrictions
Trifloxysulfuron
No
Registration
pending
for
tomatoes
*
Yes
=
Registered
for
use;
No
=
Not
registered
for
use.

Additional
notes
on
specific
herbicides
listed:
Halosulfuron­
methyl
In
December
2002,
halosulfuron­
methyl
(
Sandea
®
)
was
registered
for
weed
control
(
including
nutsedge)
in
tomatoes,
peppers,
eggplant,
and
cucurbits.
This
recent
registration
was
not
on
the
list
of
alternatives
from
MBTOC
and
several
years
are
needed
to
see
if
it
will
be
adopted.
Historically,
in
the
United
States
it
has
taken
three
to
five
years
for
an
herbicide
to
be
adopted
by
a
significant
number
of
vegetable
crop
growers.

Halosulfuron­
methyl
has
a
number
of
limitations
which
may
affect
its
widespread
adoption,
that
include:
(
1)
phyto­
toxicity
with
moderate
rainfall
immediately
after
application;
(
2)
cool
temperatures,
(
3)
susceptible
varieties,
and
(
4)
plant
back
restrictions.
Specifically:
 
Rainfall
or
sprinkler
irrigation
greater
than
2.5
cm,
soon
after
a
pre­
emergent
application
of
halosulfuronmethyl
may
cause
crop
injury.
Sudden
storms
with
greater
than
2.5
cm
of
rainfall
are
common
in
Florida
and
other
areas
of
the
southeastern
United
States.
In
addition,
rainfall
within
four
hours
after
a
postemergence
application
of
halosulfuron­
methyl
may
reduce
effectiveness
and
cause
crop
injury.
 
Under
cool
temperatures
that
can
delay
early
seedling
emergence
or
growth,
halosulfuron
methyl
can
cause
injury
or
crop
failure.
This
is
especially
likely
to
occur
during
the
first
planting
of
the
season.
In
addition,
not
all
hybrids/
varieties
of
tomatoes
have
been
tested
for
sensitivity
to
halosulfuron­
methyl.
Halosulfuron
may
also
delay
maturity
of
treated
crops.
 
Halosulfuron
methyl
plant
back
restrictions
are
up
to
36
months.
Many
of
the
vegetable
crops
fall
within
the
4
to
12
month
range,
although
some
are
longer.
There
are
label
limitations
for
halosulfuron
methyl.
As
per
product
label,
halosulfuron
methyl
should
not
be
applied
if
the
crop
or
target
weeds
are
under
stress
due
to
drought,
water
saturated
soils,
low
fertility,
or
other
poor
growing
conditions.
This
herbicide
can
not
be
applied
to
soil
that
has
been
treated
with
organophosphate
insecticides.
Foliar
applications
of
organophosphate
insecticides
may
not
be
made
within
21
days
before
or
7
days
after
halosulfuron
methyl
application.

Note:
All
the
limitations
above
are
listed
in
the
US
registration
label
for
halosulfuron,
which
in
turn
is
based
on
proprietary
data
submitted
to
EPA
by
the
registrant
company.
Pebulate
It
is
no
longer
registered
in
the
United
States.
Page
10
S­
metolachlor
It
was
registered
for
use
in
tomatoes
in
April
2003.
However,
it
is
not
registered
in
states
of
concern,
and
does
not
control
purple
nutsedge
or
nightshade
species.
Further,
it
does
not
provide
commercially
acceptable
weed
control
in
plasticulture
systems.
Glyphosate
It
is
a
non­
selective
herbicide
used
to
control
weeds
in
row
middles.
Application
to
the
rows
would
cause
injury
to
the
tomato
crop.
As
a
preplant
treatment
glyphosate
will
not
provide
season
long
control
of
yellow
and/
or
purple
nutsedge
in
tomatoes.
Paraquat
Paraquat
is
a
non­
selective
herbicide
that
controls
annual
weeds
in
row
middles.
It
may
also
be
applied
preemergence
to
the
crop.
Application
to
the
rows
would
cause
injury
to
the
tomato
crop.
For
perennial
weeds,
such
as
nutsedge,
it
will
burn
down
the
top
portion
of
the
plant
but
the
tubers
remain
viable,
allowing
the
weed
to
grow
again.
Therefore,
paraquat
will
not
provide
season
long
control
because
the
weed
can
regrow
during
the
growing
season.
Rimsulfuron
There
is
evidence
that
rimsulfuron
only
provides
suppressive
control
of
yellow
nutsedge
(
40
to
70
percent
control)
(
Nelson
et
al,
2002).
In
addition,
the
label
warns
against
tank
mixing
with
organophosphate
insecticides
because
injury
to
the
crop
may
occur.
Also,
for
most
of
the
vegetable
crops
besides
tomatoes
there
is
a
12­
month
plant
back
restriction.
This
plant
back
restriction
can
seriously
compromise
the
needed
rotational
interval
needed
for
IPM
programs.

TABLE
6.
FUMIGANT
ALTERNATIVES
TO
METHYL
BROMIDE
FOR
POLYETHYLENE­
MULCHED
TOMATO
(
LOCASCIO
ET
AL.,
1997)

Chemicals
Rate
(/
ha)
Nutsedge
(#/
m2)
Yield
(
ton/
ha)
%
Yield
Loss
(
compared
to
MB)

Nontreated
­
300
a­
c
20.1
f
59.1%

MeBr
+
Pic
67­
33
390
kg
90
e
49.1
a
­

Telone
+
Pic
(
C­
17)
327
L
340
a
34.6
bc
29.5%

Telone
+
Pic
(
C­
17)
+
Peb*
327
L
+
4.5
kg
150
de
42.5
ab
13.4%

Notes:
Numbers
followed
by
the
same
letter
(
in
columns)
are
not
significantly
different
at
the
0.05%
level
of
probability.
For
details
please
original
citation
listed
in
references.

The
U.
S.
nominations
have
attempted
to
differentiate
between
low
to
moderate
and
moderate
to
severe
pest
infestations.
For
example,
season
long
interference
between
nutsedge
and
tomatoes
resulted
in
a
marketable
yield
loss
of
10
percent
at
nutsedge
density
of
25­
nutsedge
plants/
m2.
In
addition,
to
avoid
yield
losses
above
5%,
the
crop
must
be
yellow
and
purple
nutsedge
free
during
the
period
of
2
to
10
weeks
after
transplanting.
To
avoid
yield
losses
above
10%,
yellow
nutsedge
must
be
suppressed
during
the
period
of
4
to
9
weeks
after
transplanting,
and
for
purple
nutsedge,
the
period
of
3
to
6
weeks
after
transplanting
(
Stall
and
Morales­
Payan,
2003).
In
a
greenhouse
study,
yield
loss
was
44%
for
tomato
at
a
purple
nutsedge
density
of
200
plants/
m
²
(
Morales,
et
al.,
1997).

HISTORICAL
EMISSION
REDUCTION
&
MB
DOSAGE
RATES
All
states/
regions
are
continuing
to
test
formulations
with
lower
proportions
of
MB,
as
well
as
methods
for
using
higher
barrier
tarps
(
see
VIF
discussion
below).

In
Florida,
the
MB
dosage
rate
under
tarped
beds
in
1997
was
220
Kg/
ha.
By
2002,
the
MB
dosage
rate
under
tarped
beds
had
dropped
to
160
Kg/
ha.
All
areas
in
Florida
inject
MB+
Pic
formulation
31
 
46
centimeters
below
the
soil
surface
and
beds
are
built
above
the
soil
surface
Page
11
and
tarped,
so
the
formulation
is
injected
46
 
61
centimeters
below
the
surface
of
the
tarped
bed.
The
success
in
lowering
the
dosage
rate
is
due
principally
to
a
switch
from
a
98:
2
formulation
to
a
67:
33
formulation,
but
is
also
due
to
a
reduction
in
application
rates.

In
the
Southeastern
U.
S.,
the
MB
dosage
rate
under
tarped
beds
in
1997
was
210
Kg/
ha.
By
2002,
the
MB
dosage
rate
under
tarped
beds
had
dropped
to
150
Kg/
ha.
All
areas
growing
tomatoes
in
the
Southeastern
U.
S.
inject
MB+
Pic
formulation
31
 
46
centimeters
below
the
soil
surface
and
beds
are
built
above
the
soil
surface
and
tarped,
so
the
formulation
is
injected
46
 
61
centimeters
below
the
surface
of
the
tarped
bed.
The
success
in
lowering
the
dosage
rate
is
due
principally
to
a
switch
from
a
98:
2
formulation
to
a
67:
33
formulation.

In
Georgia,
data
was
gathered
on
the
MB
dosage
rate
under
tarped
beds
since
1992.
In
1992,
the
MB
dosage
rate
below
tarped
beds
was
340
Kg/
ha.
By
2002,
the
MB
dosage
rate
under
tarped
beds
had
dropped
to
150
Kg/
ha.
All
areas
growing
tomatoes
in
the
Georgia
inject
MB+
Pic
formulation
approximately
30
centimeters
below
the
surface
of
the
tarped
bed.
The
success
in
lowering
the
dosage
rate
is
due
principally
to
a
switch
from
a
98:
2
to
a
67:
33
formulation,
but
also
was
accomplished
through
a
reduction
in
application
rates
since
1992.

In
Virginia,
the
MB
dosage
rate
under
tarped
beds
has
been
approximately
230
kg/
ha
between
1997
and
2002.
Farmers
growing
tomatoes
in
Virginia
knife
the
MB+
Pic
formulation
approximately
23
centimeters
below
the
soil
surface
and
beds
are
built
above
the
soil
surface
and
tarped,
so
the
formulation
is
injected
about
41
centimeters
below
the
surface
of
the
tarped
bed.
In
1997,
100%
of
tomato
growers
were
using
a
98:
2
formulation,
by
2001
and
2002
all
had
shifted
to
a
67:
33
formulation,
with
some
testing
the
50:
50
formulation.

In
Michigan,
95%
of
vegetable
growers
nominated
were
already
using
a
67:
33
formulation
of
MB+
Pic
in
1997
and
the
remaining
were
using
a
98:
2
formulation.
By
2000,
5%
of
growers
were
using
the
50:
50
formulation
with
the
remaining
95%
using
the
67:
33
formulation.
Although
there
was
a
shift
to
formulations
with
lower
MB,
growers
found
they
needed
to
increase
application
rates
due
to
the
explosion
of
Phytophthora
capsici.
In
Michigan,
the
MB
dosage
rate
for
all
fresh
vegetables
has
been
between
380
­
480
Kg/
ha
in
the
period
since
1997,
when
the
Phytophthora
capsici
population
exploded.
The
MB+
Pic
formulations
are
injected
approximately
31
centimeters
below
the
tarped
beds
that
are
used
to
grow
all
fresh
vegetables
in
Michigan.

VIRTUALLY
IMPERMEABLE
FILM
(
VIF)
TARPS
Although
many
sectors
are
continuing
to
test
VIF
tarps
in
trials
throughout
the
country,
at
this
time
VIF
tarps
are
generally
not
technically
and
economically
feasible
for
the
following
reasons:

Disposal
Issues

Landfill
disposal
of
VIF
and
VIF
burning
have
come
under
increasing
restrictions
in
some
jurisdictions
(
e.
g.,
California,
Department
of
Pesticide
Regulation,
00­
001;
Florida
 
62­
256.300
F.
A.
C.)


Both
landfilling
and
disposal
are
labor­
intensive
and
costly.
Page
12

Ingredients
in
VIF
limit
recycling
into
end­
use
products.

Cost

Average
cost
of
VIF
tarps
is
$
580/
acre,
whereas
average
cost
of
low­
density
polyethylene
(
LDPE)
tarps
is
$
275/
acre,
and
high­
density
polyethylene
(
HDPE)
tarps
is
$
393/
acre.


Farmers
in
some
regions
report
VIF
tarp
removal
and
disposal
costs
of
more
than
$
240
per
acre
compared
to
removal
and
disposal
costs
of
approximately
$
60
per
acre
for
tarps
used
in
flat
fumigation.

Environmental
Consequences

Inorganic
bromide
residues
in
soil
are
higher
when
VIF
tarps
are
used;
further,
the
hydrolysis
of
MB
in
water
may
result
in
the
accumulation
of
bromide
ions,
thus
increasing
the
chances
for
groundwater
contamination.


Evidence
suggests
that
VIF
tarping
could
actually
lead
to
increased
levels
of
emissions
when
the
tarps
are
removed,
thus
increasing
exposure
to
workers
and
nearby
structures.

VIF
Supply
&
Demand
Logistics

VIF
tarps
are
currently
manufactured
only
in
Europe,
and
current
VIF
tarp
production
capacity
in
Europe
is
not
high
enough
to
meet
U.
S.
demands.


VIF
tarps
manufactured
in
Europe
do
not
meet
U.
S.
application
size
and
criteria.


European
firms
are
unlikely
to
make
the
investment
necessary
to
ensure
a
viable
supply
of
adequate
VIF
tarps
to
U.
S.
farmers
before
the
2005
phase
out
date.

VIF
Challenges
to
Agricultural
Practices

A
glue
to
join
sheets
of
VIF
is
still
not
available.


Increasing
cover
times
with
VIF
to
between
10­
20
days
can
disrupt
double­
cropping
schedules
and
cause
growers
to
miss
optimum
marketing
windows.


Photo­
degradation
of
VIF
makes
it
brittle
and
ineffective
at
controlling
weeds
over
months
of
double
cropping
systems
(
current
non­
VIF
tarps
remain
on
beds
for
12­
15
months
after
one
MB
fumigation)
Page
13
MARKET
WINDOW
INFORMATION
The
series
below
indicate
the
importance
of
considering
market
windows,
and
the
concomitant
large
difference
in
prices
that
accompany
them,
when
deciding
if
alternatives
to
MB
are
economically
feasible.
Although
such
detailed
series
are
not
available
for
all
crops,
both
tomatoes
and
strawberries
demonstrate
large
fluctuations
in
prices
over
three
week
intervals
from
peak
price
to
the
midseason
price.
This
pattern
is
also
observable
for
other
fresh
fruit
and
vegetable
crops.

Prices
received
by
strawberry
growers
rapidly
decline
from
their
early
season
peak.
The
average
price
received
by
Florida
Strawberry
growers
dropped
30%
between
February
and
March
in
1999,
37%
in
2000,
and
40%
in
2001.
In
California
strawberry
prices
declined
in
this
time
period
19%
in
1999,
29%
in
2000,
and
23%
in
2001.

The
existence
of
these
sharp
declines
in
prices
which
occur
after
a
short
period
of
high
prices
(
a
period
know
as
`
the
market
window')
ensure
that
revenue
losses
caused
by
the
longer
plant­
back
periods
required
when
using
certain
alternatives
will
not
be
proportional
to
the
lost
production
time
but
will,
rather,
be
amplified
by
the
lower
commodity
price
of
the
post­`
market
window'.
The
result
is
a
decline
in
crop
revenue,
which
in
the
case
of
Florida
strawberries
would
be
approximately
40%
of
gross
revenue
apart
from
any
losses
due
to
reduced
production.

Fresh
strawberries
(
winter
and
spring),
prices
received
per
cwt,
monthly,
2001
Source,
NASS
Annual
Price
Report
2002
$
0.00
$
20.00
$
40.00
$
60.00
$
80.00
$
100.00
$
120.00
$
140.00
$
160.00
$
180.00
$
200.00
Jan­
01
Feb­
01
Mar­
01
Apr­
01
May­
01
Jun­
01
Jul­
01
Aug­
01
Sep­
01
Oct­
01
Nov­
01
Dec­
01
FL
CA
Page
14
Fresh
strawberries
(
winter
and
spring),
prices
received
per
cwt,
monthly,
1999
­
2001
Source,
NASS
Annual
Price
Report
2002
$
0.00
$
20.00
$
40.00
$
60.00
$
80.00
$
100.00
$
120.00
$
140.00
$
160.00
$
180.00
$
200.00
Jan­
99
Mar­
99
May­
99
Jul­
99
Sep­
99
Nov­
99
Jan­
00
Mar­
00
May­
00
Jul­
00
Sep­
00
Nov­
00
Jan­
01
Mar­
01
May­
01
Jul­
01
Sep­
01
Nov­
01
FL
CA
Though
the
pattern
is
not
as
well
defined,
prices
for
tomatoes
follow
a
similar
cycle.
Three
weeks
is
the
added
plant­
back
time
required
when
using
1,3­
D
or
chloropicrin.
When
using
MITC
generators,
recommended
plant­
back
can
increase
to
six
weeks.

Fresh
tomatoes,
prices
received
per
cwt,
monthly,
2001
Source,
NASS
Annual
Price
Report
2002
$
0.00
$
10.00
$
20.00
$
30.00
$
40.00
$
50.00
$
60.00
Jan­
01
Feb­
01
Mar­
01
Apr­
01
May­
01
Jun­
01
Jul­
01
Aug­
01
Sep­
01
Oct­
01
Nov­
01
Dec­
01
FL
CA
Page
15
Fresh
tomatoes,
prices
received
per
cwt,
monthly,
1999
­
2001
Source,
NASS
Annual
Price
Report
2002
$
0.00
$
10.00
$
20.00
$
30.00
$
40.00
$
50.00
$
60.00
Jan­
9
9
Mar­
99
May­
99
Jul­
99
Sep­
99
Nov­
99
Jan­
00
Mar­
00
May­
00
Jul­
00
Sep­
00
Nov­
00
Jan­
01
Mar­
01
May­
01
Jul­
01
Sep­
01
Nov­
01
FL
CA
DEFINITIONS
THAT
MAY
BE
RELEVANT
TO
THIS
CUN
Source
of
yield
loss
estimates
Where
published
studies
of
yield
losses
under
conditions
of
moderate
to
severe
key
pest
pressure
were
not
available
(
the
situation
for
which
the
United
States
is
requesting
continued
use
of
MB),
the
United
States
developed
such
estimates
by
contacting
university
professors
conducting
experiments
using
MB
alternatives
in
the
appropriate
land
grant
institutions.
The
experts
were
asked
to
develop
such
an
estimate
based
on
their
experience
with
MB
and
with
alternatives.
The
results
of
this
process
were
used
when
better
data
were
not
available.

Source
of
buffer
restriction
implications
for
methyl
bromide
use
Estimates
of
the
impact
of
buffers
required
when
using
some
MB
alternatives
on
the
proportion
of
acreage
where
such
alternatives
could
be
used
were
developed
from
confidential
information
submitted
to
EPA
in
support
of
a
registration
application
for
a
MB
alternative.
Because
at
the
time
of
the
analysis,
a
request
to
reduce
the
size
of
the
required
buffer
for
some
alternatives
was
under
consideration,
a
smaller
buffer
was
selected
for
the
analysis.
Since
that
time
the
size
of
the
regulatory
buffer
has
been
reduced
so
that
it
now
conforms
to
the
buffer
selected
for
the
analysis.

Source
of
area
impacted
by
key
pests
estimates
One
of
the
important
determinants
of
the
amount
of
methyl
bromide
requested
has
been
the
extent
of
area
infested
with
`
key
pests',
that
is,
pests
which
cannot
be
controlled
by
alternatives
to
methyl
bromide
when
such
pests
are
present
at
moderate
to
severe
levels.
Because
there
are
few
surveys
that
cover
substantial
portions
of
the
areas
for
which
methyl
bromide
is
requested,
we
have
relied
on
a
variety
of
sources
in
addition
to
the
surveys.
These
sources
include
websites
of
land
grant
universities;
discussions
with
researchers,
both
those
employed
by
USDA
in
the
Agricultural
Research
Service
(
ARS)
and
those
at
land
grant
universities;
discussions
with
growers
whose
operations
cover
widely
different
locations
encompassing
different
incidences
of
key
pests;
information
from
pesticide
applicators;
and,
information
taken
from
the
applications
themselves.

Source
of
area
impacted
by
regulations
estimates
There
are
two
main
sources
used
to
develop
the
estimate
of
area
impacted
by
regulations.
First,
for
the
impact
of
Township
caps
in
California
we
have
used
a
series
of
papers
by
Carpenter,
Page
16
Lynch,
and
Trout,
cited
below,
supplemented
by
discussions
with
Dr.
Trout
to
ensure
that
any
recent
regulatory
changes
have
been
properly
accounted
for.
Second,
the
estimate
of
the
area
impacted
by
buffers,
is
described
above.

Source
of
area
impacted
by
soil
type
estimates
First,
for
the
area
impacted
by
karst
topography,
estimates
were
developed
and
mapped
by
he
Florida
Department
of
Environmental
Protection.
The
area
of
California
used
for
agriculture
and
which
is
made
of
clay
soils
unsuitable
for
pest
control
with
a
methyl
bromide
alternative
has
been
determined
by
discussions
with
agricultural
researchers
and
agricultural
extension
agents
in
California,
and
discussion
with
other
knowledgeable
individuals
such
as
pesticide
applicators.
The
estimates
for
California
understate
the
areas
in
which
alternatives
to
methyl
bromide
are
not
suitable
because
no
effort
was
made
to
estimate
the
extent
of
hilly
terrain
where
currently
available
substitutes
cannot
be
applied
at
uniform
dosages.

Source
of
area
impacted
by
combined
impacts
estimate
Combined
impacts
were
determined
on
a
case
by
case
basis
for
each
specific
crop/
location
combination
after
consultation
with
individuals
knowledgeable
with
the
specific
circumstances.
The
nature
of
the
individual
impacts
is
such
that
in
some
situations
they
are
independent
of
each
other,
in
some
they
are
mutually
exclusive,
and
in
some
cover
identical
areas.
It
was
not,
therefore,
possible
to
have
a
formula
that
would
arrive
at
an
appropriate
estimate
of
combined
impacts.
A
more
complete
description
is
found
in
the
footnotes
to
the
`
calculation'
table.

REFERENCES:

Banks,
H.
J.
2002.
2002
Report
of
the
Methyl
Bromide
Technical
Options
Committee,
2002
Assessment.

Carpenter,
Janet,
Lori
Lynch
and
Tom
Trout.
2001.
Township
Limits
on
1,3­
D
will
Impact
Adjustment
to
Methyl
Bromide
Phase­
out.
California
Agriculture,
Volume
55,
Number
3.

Locascio,
S.
J.,
J.
P.
Gilreath,
D.
W.
Dickson,
T.
A.
Kucharek,
J.
P.
Jones,
and
J.
W.
Noling.
1997.
Fumigant
alternatives
to
methyl
bromide
for
polyethylene­
mulched
tomato.
HortScience
32
(
7):
1208­
1211.

Morales,
J.
P.,
B.
M.
Santos,
W.
M.
Stall,
and
T.
A.
Bewick.
1997.
Effects
of
Purple
Nutsedge
(
Cyperus
rotundus)
on
Tomato
(
Lycopersicon
esculentum)
and
Bell
Pepper
(
Capsicum
annuum)
Vegetative
Growth
and
Fruit
Yield.
Weed
Technol.
11
672­
676.

Nelson,
Kelly
A.
and
Karen
A.
Renner.
2002.
Yellow
Nutsedge
(
Cyperus
esculentus)
Control
and
Tuber
Production
with
Glyphosate
and
ALS­
Inhibiting
Herbicides.
Weed
Technology,
Vol.
16,
No.
3,
pp.
512­
519.

Stall,
W.
M.,
and
J.
P.
Morales­
Payan.
2003.
The
Critical
Period
of
Nutsedge
Interference
in
Tomato,
Florida.
Web
address:
http://
www.
imok.
ufl.
edu/
liv/
groups/
IPM/
weed_
con/
nutsedge.
htm
Page
17
U.
S.
Environmental
Protection
Agency,
1998.
Reregistration
Eligibility
Decision
(
RED)
1,3
Dichloropropene.
Available
at
http://
www.
epa.
gov/
REDs/
0328red.
pdf
U.
S.
Environmental
Protection
Agency,
January
26,
1998,"
Feasibility
of
Using
Gas
permeable
Tarps
to
Reduce
Methyl
Bromide
Emissions
Associated
with
Soil
Fumigation
in
the
United
States."
